Poland’s Senate restores a 22% corporate tax proposal for large taxpayers

Amendment 5 in Senate print 883Z would add Article 19(1)(6) to the Act of 15 February 1992 on Corporate Income Tax. The 22% rate would apply if the taxpayer’s preceding-year revenue exceeded €50 million, or if it was a constituent entity of a domestic or multinational group covered by the 6 November 2024 top-up tax Act on any day of that preceding year. For a Polish tax capital group, the constituent-entity condition refers to a member company. The specified banking-sector rates in Article 19(1)(3) and (4) would take priority.^[3]

Revenue, periods and restructurings

The threshold would use the National Bank of Poland’s average euro rate for the last working day of the revenue year, rounded to PLN 1,000. Non-12-month years have a proportional threshold. Separate rules extend the rate to specified divisions and capital contributions involving more than 10% of assets, mergers and newly formed tax capital groups where the statutory predecessor conditions are met. Country presence alone does not establish any of these conditions.^[3]

Simplified advance payments

Proposed Article 25(6c) would increase simplified monthly advances by 15.8% where a 22% taxpayer’s reference return used the 19% rate. The reverse rule would reduce advances by 13.6% where a taxpayer using 19% relies on a 22% reference year. The upward adjustment excludes the portion of a tax capital group’s tax subject to the specified banking rate. These are payment-calculation changes, not newly prescribed calendar deadlines.^[3][4]

Amendment 10 would apply the CIT changes to income or revenue of tax years beginning after 31 December 2026. The Senate approved the linked amendments 1, 5, 9 and 10 by 62 votes to 23, with no abstentions. This is a parliamentary proposal, not an enacted rate increase. Groups should confirm the final legislation, preceding-year revenue and statutory group status, any restructuring and the relevant tax year before changing payments.^[1][2][3]